Human Rights Diligence at Covestro

Covestro is committed to respecting and safeguarding human rights on the basis of the United Nations Guiding Principles on Business and Human Rights (UNGPs). We acknowledge our responsibility to respect human rights throughout the Covestro Group, in subsidiaries and in global supply and value chains and to prevent human rights violations.

We have long integrated human rights aspects into the various management systems within our company. Our cross-departmental Human Rights Office is responsible for driving the due diligence approach at Covestro in line with the UNGPs and national legislations like the German Act on Corporate Due Diligence Obligations for the Prevention of Human Rights Violations in Supply Chains.

The Human Rights Office works under the leadership of the corporate Sustainability & Public Affairs function and has permanent members from the following corporate functions: Group Health, Safety and Environment, Group Procurement, Human Resources, Law, Intellectual Property & Compliance.

As a company, we clearly take responsibility for respecting human rights in all of our activities and throughout global supply chains and value chains. Our human rights due diligence is embedded in the human rights management system implemented at Covestro.

The overarching management system comprises the six core elements described below.

• The principles of our human rights due diligence are delineated in various Corporate Commitments, corporate regulations, and in our Supplier Code of Conduct.
• In these documents, we have specified key international conventions and principles as the basis of our conduct. We expect the conduct of our employees and business partners worldwide to comply with these basic principles.
• A key component of our commitment is zero tolerance toward child labor, forced labor, and human trafficking. One example is our public statement on slavery and human trafficking (“Corporate Commitment against Slavery and Human Trafficking”) to underline our position.
• Further information on our Corporate Commitments and Policies can be found here.

• The starting point for human rights due diligence is a risk analysis that identifies and assesses actual or potential negative impacts on human rights that Covestro could cause as a result of its business activities.
• The comprehensive and ongoing risk analysis covers all of the production and distribution sites of Covestro, the supply chain, as well as the use phase and end-of-life of our products.
• Potential human rights violations assigned the highest degree of severity always take top priority for us.
• Ad hoc risk analyses are performed in an event-based manner. Also, internal and external findings may trigger a reassessment of our human rights risks.

• Following the risk-based approach recommended by the UN, we assess the suitability of our existing measures for the prioritized areas where Covestro may cause, contribute to, or is directly linked to negative impacts on human rights.
• Many measures in the areas of health and safety, product stewardship, compliance, human resources, and sustainable supplier management have long been integrated at Covestro and aim to prevent or mitigate negative human rights impacts.
• As needed, we complement the existing measures, to close gaps and continuously improve.

• Appropriate qualitative and quantitative indicators, along with internal and external sources, are used to assess the human rights measures at Covestro, aiming to review their effectiveness in preventing negative impacts on human rights.
• The corporate functions represented in the Human Rights Office report on the implemented measures and potential findings regarding their effectiveness.

• Covestro expressly encourages reporting of possible human rights violations in the Group as well as at suppliers’ companies. We use a whistleblower tool for reporting violations which consists of a worldwide hotline and an online tool.
• We investigate cases of suspected human rights violations by following a defined process based on the involvement of (potentially) affected stakeholders.
• Further information on our Corporate Grievance Mechanism can be found here.

• Every year, Covestro communicates its human rights activities to the public in its annual report.
• The Human Rights Office reports regularly (no less than once a year) to the Board of Management on the performance of its human rights due diligence and the systematic integration of these requirements into the management systems at Covestro.
• In line with the requirements of the German Supply Chain Act, a report on the fulfilment of the due diligence obligations by Covestro for the previous fiscal year will be published on its external website in the year 2024.